Web & Mobile Privacy Statement

Welcome to Company’s web and mobile experience. This Company Web & Mobile Privacy Statement (the “Privacy Statement”) describes our practices in connection with information we collect through software applications (including mobile applications) and websites that we operate and that contain a link to this Privacy Statement (an “Application” or, together, the “Applications”). This Privacy Statement is designed to transparently describe our privacy practices, in a format that is easy to navigate, read, and understand. We are committed to treating your information with care and respect and managing our Applications in a manner which is compliant with law.

As you navigate our Applications and communicate with Company (sometimes referred to as “we” “us” or “our”) via the Applications, we may ask you to disclose certain information so that we can provide you with the highest quality information and services. In order for you to make an informed decision about whether to disclose your information to us via the Applications, we are providing you with the following information about how we collect and use your information.

This Privacy Statement describes our practices in connection with information we collect through Applications that contain a link to this Privacy Statement. We are not responsible for the privacy practices of any third party service providers (such as Internet Service Providers (“ISPs”) or cloud service providers) or other third parties operating websites or applications to which the Applications link. The inclusion of a link on Company’s Application does not imply that Company endorses, or otherwise monitors the privacy practices of that linked third party website or application.

We may collect two basic types of information: Personal Information and Non-Personally Identifiable Information. By “Personal Information,” we mean data that is unique to an individual, such as a name, address, PAN Number, e-mail address, telephone / mobile number, family members info and certain personal device information, as described below. By “Non-Personally- Identifiable Information,” we mean information that does not identify you personally, but can provide us with usage data, either individually or in the aggregate. Non-Personally Identifiable Information may include demographic information, aggregated information, certain information collected automatically through your device such as web browser information, server log files, cookie technology, pixel tags or beacons, and other technologies, and other non-personally identifiable information collected by us or provided by you.

We acquire Personal Information when you voluntarily register or create a personal profile with us, or request products, services, or information from us. We may also automatically collect certain personal device information – such as physical location, IP address, application activity, data usage and malware information – to authenticate you and/or your personal device for purposes of Application security and to help prevent fraud and data loss. In some cases, and in all cases where required by law or regulation, you will be able to update the information that you provide to us either by sending us an e-mail or, where you have established personal profiles with us, by updating your profile online.We may use Personal Information for the following purposes:

· Verifying your identity so that we can be sure that all of our communications with you are secure and confidential, for Application security,

and to help prevent fraud and data loss;

· Responding to inquiries or requests from you;

· For audit and quality purpose, to improve our services and allowing us to serve your better.Delivering web-based products and services to

you, such as our health risk assessment.

· To send you marketing and promotional communications that we believe may be of interest to you, if permitted by law.

Except in connection with the sale, transfer, merger, consolidation or other transaction involving all or part of our company, we will not sell, license or otherwise transfer any rights to your personal information to any third party unless expressly authorized by you. We may transmit or disclose your Personal Information to third parties for the following purposes:

· If required by law or any competent authority, in response to any summon, regulatory oversight, or other legal process;

· To enable Company’s contractors or vendors to perform certain services for us, including, but not limited to, Application maintenance and

performance improvement tasks.

This Application will not knowingly collect personally-identifiable information from minors under the age of eighteen (18) without their parents’ consent.

When you visit or use our Applications, we collect certain Non-Personally- Identifiable Information and aggregate information about you. This data helps us to analyze and improve the usefulness of the information and services we provide through our Applications. Because Non-Personally Identifiable Information does not personally identify you, we may use and disclose such information for any purpose permitted by law, including:

· We may automatically collect certain web browser information. Web browsers collect and store information about the type of device and

operating system you are using to access our Applications, as well as your device’s media access control (“MAC”) address for facilitating

network communications. Accessing this information helps us to establish a secure and consistent connection to you and to customize

experience and content when you use our Applications.

·“Cookie” technology. A "cookie" is an element of data that we can send to your browser when you link to our Applications. It is not a

computer program and has no ability to read data residing on your computer or instruct it to perform any step or function. By assigning a

unique data element to each visitor, our Applications are able to recognize repeat users, track usage patterns and better serve you when

you return at a later time. The cookie does not extract Personal Information.

· Client-side page tagging. This technology uses code on each web page to write certain information about the page and the visitor to a log

when a page is rendered to you by our Applications. "Tagging" does result in a JavaScript program running in your browser, but it is limited to

providing information about the page that you are requesting and the configuration of your browser. It will not read any of your data files, nor

execute any additional programs. It does not extract any Personal Information about you. You can prevent tagging by disabling JavaScript in

your browser, but that may prevent you from using all of our Applications’ functions.

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect your information from unauthorized access, disclosure, use and modification. We regularly review our security practices to consider appropriate new technology and methods. We also periodically subject our Applications to simulated intrusion tests. However, please be aware that despite our best efforts, no security measures are perfect or impenetrable.

We welcome your comments or questions about our Applications and have provided e-mail boxes in Contact Us section for that purpose. We will share your comments and questions with our customer service representatives for addressing your questions and concerns. Please note that your e-mail, like most, if not all, non-encrypted Internet e-mail communications, may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to us. If you wish, you may contact us instead via telephone at the numbers provided in the Contact Us section or, in the case of our health plan members, at the toll-free number that appears on your membership card.

From time to time, our Applications may provide links to other websites or applications, not owned or controlled by the Company, that we think might be useful or of interest to you. We cannot, however, be responsible for the privacy practices used by other website owners or the content or accuracy of those other websites. Links to various non-Company’s websites or applications do not constitute or imply endorsement by the Company of these websites or applications, any products or services described on these sites, or of any other material contained in them. We may also provide links to other websites or mobile applications that are controlled by an Aetna-owned company, but that operate independently of the Applications. Privacy policies applicable to those sites and applications will appear on those sites and applications and may differ from this Company's Privacy Statement.

Company may change this Privacy Statement from time to time; when updates are made, the version date (located at the bottom of this Privacy Statement) will also be updated to reflect that a revision occurred. We encourage you to periodically review this Privacy Statement to see if there have been any changes that may affect you. This Privacy Statement is not intended to and does not create any contractual or other legal rights in or on behalf of any party.